A comprehensive Food Safety Plan is the key to compliance with the Food Safety Modernization Act. Instead of taking a reactive stance towards safety issues, producers are now required to seek out and mitigate potential risks before they become an issue. We sat down with Roberto Bellavia, Senior Consultant and Principal at Kestrel Management, to discuss the top five do’s and don’ts for creating your Food Safety Plan.
- Develop Your Staff and Invest in Training: “Food Safety isn’t a one-man show,” Roberto tells us. Your Qualified Individual can’t do it alone. They will need support from the entire staff. “The safest facilities have embedded a culture of food safety at every level. The workers on the production floor are the ones that are actually bringing these programs to life.”
- Take a Scientific Approach: Too many facilities are oblivious to their potential hazards. “Just because you’ve never had a problem doesn’t mean you’re a low-risk facility,” Roberto says. “Your Food Safety Plan needs to proactively search for potential sources of contamination before they become an issue.”
- Understand Your Product and Supply Chain: The FSMA’s requirements don’t end at the loading dock. “You need to have a perfect understanding of your entire supply chain,” Roberto tells us. “A good plan will document the origin and chain of custody for every shipment of raw ingredients. You also need to keep track of where your finished products are headed and what they’re being used for. You need to develop and practice a recall plan that can locate every shipped product at a moment’s notice.”
- Familiarize Yourself with All Regulations: Your Food Safety Plan has to cover every step of production. Every procedure and piece of equipment needs to undergo a risk analysis and be brought into compliance with the FDA’s Current Good Manufacturing Practices.
- Document Everything: The FSMA also brings new requirements for record keeping and validation. “You can have a completely thorough Food Safety Plan, but if you aren’t documenting your implementation and testing to make sure your plan is actually addressing risks, you’re not in compliance.”
- Cut Corners on Sanitation: Good sanitation practices should form the cornerstone of your Food Safety Plan. “Every time a worker or a piece of equipment comes onto your production floor, that is a critical point that needs to be managed,” Roberto says. “If you can’t maintain the highest standards of hygiene, you aren’t shipping a wholesome product.”
- Skimp on Preventive Maintenance: Foodborne pathogens like Listeria can thrive in chipped fixtures and scratched equipment. “You have to stay on top of maintenance and eliminate any foothold for bacteria to colonize,” Roberto says. “Something as small as a cracked floor drain can lead to contamination.”
- Expose Yourself to Potential Liabilities: The easiest way to control a hazard is by eliminating it from your production process. Reducing the number of potential contamination points will allow your Food Safety Plan to focus on the most critical production areas. “You should always be searching for ways to minimize the number of times a product is handled, as well as reducing the amount of time it spends exposed to the environment.”
- Let Anything Slide: Every deviation from the Food Safety Plan requires corrective actions and preventive measures. “Mistakes are inevitable,” Roberto says, “so you need to have a procedure in place to address the issue and make sure it doesn’t turn into a pattern.”
- Grow Complacent: Roberto reminds us, “don't maintain the status quo. Food Safety, like any scientific pursuit, is constantly evolving, and managing risk is an ongoing process. If you’re not constantly improving, you’re falling behind.”